Creative Direct Marketing Group, CDMG Inc. (“Creative Direct Marketing Group, CDMG Inc.” or “we” or “us”) values your privacy and we are committed to protecting the personal information of our clients (“clients”, or “businesses”), as well as the customers of our clients (“customers” or “consumers”). To simplify the understanding of what data we collect and how it is used, we have created this privacy policy for customers/consumers of our clients. Our clients’ Privacy Policy can be viewed at this link.

Privacy Policy for our Clients’ Consumers

Please read the following to learn more about our Privacy Policy (“Policy”). By visiting the Creative Direct Marketing Group, CDMG Inc. website at CDMGinc.com (the “Website” or “Site”), or using any of our services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. Please note that all the information set out in this Policy may not apply to you. Below is an overview of the possible circumstances in which we could interact together. Our interactions with you will determine which of the following applies to you and your personal information. There are additional considerations at the end of this policy for consumers in California.

What This Privacy Policy Covers

This policy covers how Creative Direct Marketing Group, CDMG Inc. treats personal information that it receives on behalf of a client, or otherwise gathers when clients’ consumers use our services or our website. “Personal information” is information about you that is personally identifiable like your name, address, email address, or phone number. This policy does not apply to the practices of companies that Creative Direct Marketing Group, CDMG Inc. does not own or control, to third party websites (even if linked to the Website) or to people that Creative Direct Marketing Group, CDMG Inc. does not employ or manage.

Creative Direct Marketing Group, CDMG Inc. does not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to use our services or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to or on Creative Direct Marketing Group, CDMG Inc.. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, contact us at privacy@cdmginc.com.

Information We Collect from Consumers

In the course of your use of the Services, we obtain the following information about you as described below. We collect this data for the purposes described under “How We Use Your Information”.

Information you Voluntarily Provide to us:

We collect the following information from you when you provide it to us:

Information you provide prior to purchasing one of our clients’ products or services, such as your name, email, phone, address, or other service, that you are looking to purchase.

Information that you provide when you email one of our clients (for support or otherwise).

Information we may collect about your usage and devices:

We collect data relating to your online activity on our clients’ websites, including the following:

Geographic location, pages you view, the date and time you accessed those pages.

How you got to our clients’ sites, and any links you click on to leave our clients’ sites.

Metadata about your use of our Services and emails we send to you on behalf of our clients, including clicks and opens.

Metadata about how your customers, contacts, and users interact with the Services we provide you

Your interactions with any videos we offer on behalf of our clients.

Generally, our service automatically collects usage information, such as the numbers and frequency of visitors to our site and its components, similar to TV ratings that indicate how many people watched a particular show. Creative Direct Marketing Group, CDMG Inc. only uses this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often users use parts of the Website or services so that we can make the Website appealing to as many users as possible, and improve those services. As part of this use of information, we may provide aggregate information to our partners about how our users, collectively, use our site. We share this type of statistical data so that our partners also understand how often people use their services and the Website, so that they, too, may provide you with an optimal online experience. Again, Creative Direct Marketing Group, CDMG Inc. never discloses aggregate information to a partner in a manner that would identify you personally, except as otherwise provided herein.

This information is stored in a variety of places within our infrastructure, including system log files, back end databases and analytics systems.

Other information we collect and use, which may be associated with you:

We collect other data that we believe is necessary to facilitate transactions between you and our clients, including:

First name, last name, and email to deliver newsletter updates for our clients.

Address.

Telephone.

By requesting this information and providing your personally identifiable information on the website, you have given the client permission to communicate such information to you either by telephone or email.

Creative Direct Marketing Group, CDMG Inc. acts as the client’s digital marketing agent. Clientss will provide Creative Direct Marketing Group, CDMG Inc. with your personally identifiable information such that we can contact you on behalf of the client via telephone, mail or email with information. To opt out of receiving such communications, please contact privacy@cdmginc.com or the client to whom you sent the your initial inquiry, and our platform will cease all communications.

The use of Cookies and Web Beacons

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our site are visited and by how many people. Company cookies do not collect Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are or what your screen name or email address is.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways.

Creative Direct Marketing Group, CDMG Inc. may set and access cookies on your computer. These cookies allow us to recognize your computer each time we send you an online advertisement to compile information about you or others who use your computer. This information allows us to track the performance of our system and to improve the user experience. This Privacy Policy covers the use of cookies by Creative Direct Marketing Group, CDMG Inc. and does not cover the use of cookies by any advertisers.

We use third-party advertising companies to serve ads on sites on which we advertise. Third-party advertising technology (1) uses information derived from your visits to this Web site, your visits our Web sites where you’ve obtained information, and the sites on which we advertise to serve ads to you and (2) places a unique third-party cookie or cookies on your browser. In addition, we may use Web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising. Web beacons enable us to recognize a browser’s cookie when a browser visits this site, and to learn which banner ads bring users to our Web site. To “opt-out,” please click here.

Although we believe that each of the sites to which we target our ads or from which we otherwise collect data should post a privacy statement that fully describes the advertising and data collection activities on its site, we cannot guarantee that all of those sites post such a statement.

How we use Your Information

We use the information we collect, both on its own and combined with any other information we collect about you, for the following business and commercial purposes on behalf of our clients:

To provide the requested Services to you, and to ensure the proper functioning of our Services.

To offer and improve our Services

To provide you with requested information

To facilitate your movement through our clients’ websites

To do a better job of advertising and marketing our clients’ services (subject to your consent where required by applicable law);

To diagnose problems with our servers or our services;

In connection with our security and compliance programs;

To administer our applications and services that interface with our clients’ and third-party systems.

To communicate with you;

To target current or prospective customers with our clients’ products or services through online advertisements served on third-party sites by third-party vendors, such as Google (subject to your consent where required by applicable law);

To assist us in offering you a personalized experience or otherwise tailor our clients’ services to you; and as otherwise described in this privacy notice.

We also use the information we receive to produce reports on trends and statistics, such as search trends, email open rates, campaign best practices or the number of users that have been exposed to, or clicked on, our clients’ websites or evaluated or purchased our clients’ products or services.

Sharing of Information

Creative Direct Marketing Group, CDMG Inc. does not rent, sell, or share personal information about you with other people or non-affiliated companies except to provide products or services that you’ve requested, when we have your permission, or under the following circumstances:

Protection of Creative Direct Marketing Group, CDMG Inc. and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our policies; or protect the rights, property, or safety of Creative Direct Marketing Group, CDMG Inc., our employees, our users, or others. This includes, without limitation, exchanging information with other companies and organizations for fraud protection; responding to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims; and when we believe it is necessary, sharing information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or as otherwise required by law.

Agents: We work with and employ other companies and people to perform tasks on our behalf and on behalf of our clients and need to share your information with them to provide products or services to you. Examples include sending email, analyzing data, providing user services, fulfilling orders, delivering services, maintaining and operating the Website, providing marketing assistance, processing credit card payments, investigating fraudulent activity and conducting customer surveys. On behalf of our clients, we also share transaction data with Facebook, in order to understand the effectiveness of various advertising campaigns that we run for our clients. Facebook does not disclose to use the behavior of any individual users, simply trends and overall statistics that can be used to gauge the effectiveness of various campaigns. Unless we tell you differently, Creative Direct Marketing Group, CDMG Inc.’s agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.

User Queries: User profile information including, without limitation, users’ name, telephone number and email address, may be used to facilitate and provide your requested services within the Website.

Communication in response to User Queries: As part of our sites, toolbars, services, or our clients’ websites and services, you may receive from Creative Direct Marketing Group, CDMG Inc. email and other communication relating to your use of these sites or services. You acknowledge and agree that by posting information on the sites or otherwise using the websites or services, Creative Direct Marketing Group, CDMG Inc. and its agents may send you email, contact you or engage in other communication that they determine in their sole discretion relate to your profile or use of the Website. If you provide Creative Direct Marketing Group, CDMG Inc. with your telephone number, Creative Direct Marketing Group, CDMG Inc. may contact you in connection with orders or queries you have submitted on the Websites.

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if Creative Direct Marketing Group, CDMG Inc., or substantially all of its assets were acquired, or in the unlikely event that Creative Direct Marketing Group, CDMG Inc. goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Creative Direct Marketing Group, CDMG Inc. may continue to use your Personal Information as set forth in this policy.

Confidentiality and Security

We limit access to personal information about our clients’ and their consumers to employees on a need-to-know basis, meaning they need that information to provide products and services in order to do their jobs.

We have physical, electronic, and procedural safeguards that comply with federal regulations to protect personal information about you. Creative Direct Marketing Group, CDMG Inc. endeavors to protect user information to ensure that user account information is kept private and Creative Direct Marketing Group, CDMG Inc. takes that task seriously, however, Creative Direct Marketing Group, CDMG Inc. cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. For additional information about the security measures Creative Direct Marketing Group, CDMG Inc. uses in connection with the Website, contact us. Creative Direct Marketing Group, CDMG Inc. is not responsible for the privacy policies and/or practices on other sites. When linking to another site a user should read the privacy policy stated on that site. This Privacy Policy only governs information collected using our products and services.

What Other Choices Do I Have?

You can always opt not to disclose information, even though it may be needed to complete the transaction between you and our clients, or take advantage of other Creative Direct Marketing Group, CDMG Inc. features.

Specific considerations for residents of, and businesses within, the State of California.

The California Consumer Privacy Act of 2018 (CCPA) is a new data privacy law that establishes various rights for California state residents. The law applies to companies that do business in California and meet one of several criteria. CCPA requires giving residents the right to opt out of the “sale” of their “personal information” (as the law defines those terms), with the opt-out offered via a prominent “Do Not Sell My Personal Information” link on the “selling” party’s homepage. CCPA does recognize certain exceptions to the definition of “sale,” such that not all transfers of personal information are “sales.” For example, transferring personal information to a “service provider” under the law is not a sale.

Under the terms of the CCPA, Creative Direct Marketing Group, CDMG Inc. is a Service Provider, and already has numerous safeguards in place for protecting consumer information across all of our products. We do not have any product offerings that establish a direct relationship between us and any consumers. We act exclusively as a Service Provider to facilitate the interactions between our business clients, and their consumers/customers.

CCPA provides five general “rights’ for the personal information for California consumers, including:

To know what information is collected about them – This is explained above in the sections “Information we collect from consumers”, and “The use of cookies and web beacons”.

To know whether and to whom their personal information is sold/disclosed, and to opt-out of its sale – As a service provider, we collect this information on behalf of, and share with, the business with whom you are already interacting, either through a response to an online ad, or in subsequent communication.

To access their personal information that has been collected – Your consumer information exists in the systems of other businesses with whom you interacted. We have copies of that information in order to facilitate the interactions between you and the business, in case there is a communication problem sending the data to/from the business, and for analytics. The “System of Record” for your data exists at the businesses with whom you interacted.

To have a business delete their personal information – As a California consumer, if you make a request to delete information from one of our clients or other client businesses, after they validate your identity and/or the relationship you have with an agent acting on your behalf, that business will be able to remove any information on our systems. Since our products are tools that our clients use, they generally have control over all the data in our systems, and in the instances where they do not have direct control to remove customer information, we will be providing tools and services to facilitate their requests.

To not be discriminated against for exercising their rights under the Act (i.e. to receive equal service and pricing) – We are a Service Provider, with no direct relationship with any consumer, therefore it is impossible for us to discriminate in this way. We will comply with and facilitate all deletion requests from our Business customers.

For any current or previous clients of Creative Direct Marketing Group, CDMG Inc., to request the deletion of one of your consumers/customers or additional information on the data we have collected, please message us at privacy@cdmginc.com. As we do not have the direct relationship with our client’s consumers/customers, it is the client’s responsibility to verify the identity of the person(s) requesting deletion.

Changes to this Privacy Policy

Creative Direct Marketing Group, CDMG Inc. may update and make changes to this policy from time to time for any reason. Use of information we collect is subject to the Privacy Policies in effect at the time such information is used. Users are bound by any changes to the Privacy Policy when he or she uses the Website after such changes have been first posted.